On September 14, 2026 the Government of Montenegro determined the Draft Law on Amendments to the Law on Prevention of Money Laundering and Financing of Terrorism (EPA 1192 XXVIII, act 04-3/26-2, cover 11-011/26-3586/4) and sent it to Skupstina President Andrija Mandic. The draft amends the AML/CFT statute in Službeni list CG 110/23, as amended through 59/26, and aligns Montenegro with Directive (EU) 2019/1153 of June 20, 2019. The Government asks Parliament to adopt it under Article 151 of the Rules of Procedure (urgent procedure).
On September 15, 2026 Vice-President Mirsad Nurković referred the file to the Committee on Economy, Finance and Budget as lead committee (Article 43) and to the Legislative Committee (Article 39). The parliamentary register card records status "U proceduri". Article 4 CDD and SAR duties for advocates are not rewritten. The change is FIU, police and Central Bank use of financial data for Europol-list serious crime, with the heaviest register-access rules delayed until Montenegro joins the EU.
What does the 13-article bill change in the AML statute?
Article 1 inserts point 4a in Article 6(1): "serious crimes" are the forms of crime in Annex I to Regulation (EU) 2016/794 of May 11, 2016 (Europol). Point 13 is rewritten so "financial information" is any data the financial-intelligence unit holds for AML/CFT, in particular financial assets, movement of funds or financial business relationships. Article 2 rewrites Article 96(1): the FIU may collect and analyse data on a reasoned request, or on information from police, tax, Customs, the intelligence and anti-corruption agencies, the prosecutor or the Court, where there is suspicion of money laundering, a related predicate, terrorist financing or criminal proceeds, or where the analysis is needed in an individual case to prevent, detect, investigate or prosecute a serious crime. Those authorities may use the FIU response only for the purpose stated in the request. Article 4 adds an Article 107 exception for urgent FIU-to-FIU exchange without delay on terrorism or organised crime linked to terrorism.
Article 5 rewrites Article 112 so the Central Bank of Montenegro (CBCG) keeps electronic registers of accounts, rented safe-deposit boxes, and sight and term deposits at credit institutions and foreign-bank branches. Article 6 extends Article 113 to those branches and adds point 5: identifiers of the person acting for the account holder and of the holder's beneficial owner. Articles 7 and 8 create Articles 113a to 113c and 121a: the police unit designated as Montenegro's Asset Recovery Office gets direct electronic access to Article 112(3) data to identify, trace and freeze assets in serious-crime work, and may answer a justified Europol request via the national Europol unit. CBCG must auto-log every search and delete those logs after five years unless a supervision file is open.
Who is in scope now, and what waits until EU accession?
Credit institutions and foreign-bank branches are the Article 112 reporting entities. Advocates remain Article 4 obliged entities for the listed real-estate, company, asset-management, account and vehicle-formation work; the bill does not amend that list or the SAR secrecy carve-out. Article 121a binds the FIU, the Article 96 authorities and the Asset Recovery Office, not DNFBPs. Article 13 sets entry into force on the eighth day after publication in Službeni list Crne Gore. Article 12 (new Article 146b) postpones Articles 99a, 112(2) to (5), 113(1)(5), 113a to 113c and 121a until EU accession day. CBCG rulemaking under Article 112(11), the Article 99a method and the Ministry of Interior organisation act for the Asset Recovery Office are due within six months of entry into force. CBCG plus tax have 12 months to link the account and safe registers to the beneficial-owner register; CBCG plus Police have 12 months for electronic access, search and logging.
| Provision | Applies from (if adopted as filed) |
|---|---|
| Art. 6 serious-crime definition; Art. 96 FIU analysis for serious crime; Art. 107 urgent FIU-to-FIU terrorism exchange; Art. 112(1) CBCG register mandate | Eighth day after Službeni list |
| Art. 112(2) to (5) bank reporting and beneficial-owner link; Art. 113(1)(5); Arts. 113a to 113c ARO access and five-year logs; Arts. 99a and 121a statistics and request registers | EU accession day |
| CBCG rulebook, Art. 99a method, MoI organisation act for the Asset Recovery Office | Within 6 months of entry into force |
| CBCG plus tax beneficial-owner link; CBCG plus Police electronic access and logging | Within 12 months of entry into force |
What should law firms and banks do before first reading?
No committee report or first-reading date is on the register card. Treat the file as an accession-alignment statute, not a CDD rewrite. Advocates should leave Article 4 playbooks in place and map which client matters already sit inside Article 4, because the expanded FIU serious-crime analysis power can start eight days after gazette. Banks should size the Article 112 data set against current CBCG reporting and diary the 12-month technical clocks and the accession-day go-live for paragraphs 2 to 5.
Continuous, per-jurisdiction real-time monitoring surfaces a Skupstina filing the day the Government cover letter is stamped, not when Službeni list later starts the eight-day clock.
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Confirm whether you are an Article 4 obliged entity or an Article 112 credit institution, diary the eight-day gazette clock versus the Article 146b accession delay, and brief FIU-response and CBCG-reporting owners before the lead committee reports. Obsidian tracks EPA 1192 XXVIII from the September 14 deposit through committee, plenary and gazette.
